After the first revision of WEEE Directive being published in 2012, European legislators have currently once again been reassessing its effectiveness and came to a clear conclusion: Changes are needed in order to 

• Slow down the growth of WEEE 
• Improve re-use and repair in order to prolong product lifecycles 
• Set incentives for sustainable product design.

The objective is clear: To make the legislation fit for purpose for the future and aligned with the broader ambitions of the circular economy.  

This review intends to reflect the changing realities of the market, including the emergence of new technologies (such as lithium-ion batteries and increasingly miniaturised components), new product categories (such as IoT devices, wearables and e-mobility equipment), as well as evolving waste streams, characterised by growing volumes of small electronic devices, a higher share of battery-containing products, and increasingly complex material compositions. Despite the progress made, nearly half of WEEE is still not properly collected, and only around 40% is effectively recycled. 

Key Questions Shaping the Future Framework 

As the revision process unfolds, the below fundamental questions are being discussed at EU level: 

• How can a better harmonisation and simplification be achieved across the Member States. Should WEEE remain a directive or be transposed into a regulation, as previously done both for Batteries as well as Packaging? 
• With the extraordinary importance for securing secondary raw material and need for critical raw material not being broadly available in Europe: Should WEEE continue as independent legislation or become integral part of the new Circular Economy Act? 

A clear direction from the European Commission is already emerging: greater harmonisation and simplification across the EU to reduce complexity and make EPR compliance easier for producers, especially when coming from the SME sector.

What Changes Can Be Expected? 

While the final shape of the revised WEEE framework is still under development, several key changes are already becoming apparent. The revision is expected to address amongst other the below structural weaknesses and to strengthen the circular economy performance of the legislation, including:

• Higher or revised collection targets for WEEE streams
• Stronger focus on recovering critical raw materials (CRMs), which are currently insufficiently captured in existing systems
• Attempt to harmonise Extended Producer Responsibility (EPR) schemes across Member States
• Improved reporting formats and greater transparency: Reduce national fragmentation through a regulation instead of a directive to ensure aligned implementation of law in all Member States
• Stronger enforcement measures, particularly regarding online sellers and free-riders.

Harmonisation: A Shared Objective 

The idea of simplification and harmonisation is not only driven by policymakers, but also strongly supported by PRONEXA and its PRO network across Europe. It has been a core principle from the beginning, when we were founded more than 10 years ago: Simplify EPR compliance for producers across Europe. Initially focussing on WEEE and Batteries, we now also cover Packaging obligations for our customers in 29 countries, with Switzerland as country number 30 expected to come up with Packaging EPR legislation, soon. 

Although not being able to harmonise legislation by ourselves, we successfully managed to implement a system that allows to handover the existing complexity to a reliable compliance partner, who manages that complexity on your behalf. 

What It Means for Producers 

For producers of electrical and electronic equipment, the upcoming revision of the WEEE Directive is both a challenge and an opportunity. On the one hand, the expected changes will force producers to increasingly amend the well-established linear business models into new circular ones. Common efforts will also be needed to achieve longer product life, easier recovery of material and the setup of functioning markets for secondary raw material. 

Whatever Changes Will Ultimately Be Implemented

• PRONEXA and our PRO network partners are monitoring regulatory developments closely 
• We are guiding producers when adaptations are needed 
• Independent from regulatory changes, we are offering already today a highly harmonised EPR requirements handling 
• Improving data quality and reporting capabilities will be required to adapt to the further requirements to be expected. 

At the same time, companies should consider how product design, recyclability, and material recovery strategies can support future compliance requirements – particularly in light of the growing focus on critical raw materials. 

The message is just as clear for businesses: those who prepare early will be best equipped to navigate the transition and benefit from a more harmonised European system.

Join PRONEXA on this journey and get in touch via the QUICK OBLIGATION CHECK if you would like further advice. 

Currently, consumers are confronted with a wide variety of symbols – such as the French TRIMAN label or country-specific systems in Italy and Spain – which often leads to confusion and incorrect disposal. Under Article 12 of the Packaging and Packaging Waste Regulation (PPWR), a standardised sorting label will be introduced for the first time across Europe. The goal is clear: 

• Reduce consumer confusion
• Improve sorting accuracy
• Increase recycling rates
• Remove barriers within the internal market

What Will Change? 

The proposal, developed by the Joint Research Centre (JRC), introduces a system designed to create labels that are intuitive and easy to understand at the point of disposal. The European Commission will review the JRC’s technical guidance, with final requirements expected by August 2028 through a planned implementing act. 

The system focuses on three key elements: 

1. Standardised pictograms: Clear, intuitive icons will indicate how packaging should be disposed of.
2. Harmonised colour coding: Consistent colours will be used across both packaging and collection bins to guide users.
3. Clear instructions: Labels will include straightforward guidance to reduce ambiguity at the point of disposal. 
4. Digital layer: QR codes provide localised and multilingual informations. 

Importantly, accessibility is a core principle. Colour coding is intended to support – not replace – pictograms and text, ensuring usability for people with visual or cognitive impairments. 

Digital Layer: Beyond Physical Labels 

Recognising the limitations of physical packaging space, the proposal also introduces digital solutions such as QR codes. These can provide: 

• Region-specific disposal instructions 
• Multilingual guidance 
• Additional sorting information 

For producers, this opens up new opportunities to connect local infrastructure with EU-wide standards while still addressing regional differences. 

The Technical Update As a Behavioural Challenge 

While the harmonisation of labels may appear to be a technical change, it is equally a behavioural challenge. Waste sorting habits are deeply influenced by local infrastructure, cultural norms, and user understanding. A unified system will only be effective if it is widely understood and consistently applied. 

The JRC proposal reflects this complexity. It is based on extensive research, including large-scale behavioural studies, stakeholder input from across the value chain, and co-creation with citizens in multiple Member States. This collaborative approach increases the likelihood that the system will work in practice, not just in theory. 

Implementation Challenges 

Despite its potential, implementation will require careful coordination. Aligning existing national systems with a new EU-wide framework will take time, and integrating elements such as deposit return schemes adds further complexity. There are also practical considerations around label clarity, the level of detail required, and the associated costs – particularly for smaller companies. 

To address these challenges, the proposal foresees transitional periods, continued stakeholder involvement, and strong communication efforts to support user adoption. 

What It Means for Producers 

For producers, the new labelling system presents a clear opportunity to improve sorting quality and overall system performance. At the same time, it requires active engagement. Operators will need to adapt their communication, align with new standards, and support public understanding of the changes. 

Opportunities: 
• Improved sorting quality 
• Reduced contamination 
• More efficient recycling processes 
• Better alignment across borders 

Responsibilities: 
• Adapting infrastructure and communication 
• Aligning with new labelling standards 
• Supporting public education efforts 
• Collaborating with producers and policymakers 

By combining standardisation with behavioural insights and digital tools, the EU is addressing a long-standing barrier to better recycling outcomes. 

If you have any questions about the new labelling system, please reach out to our team at PRONEXA by submitting the QUICK OBLIGATION CHECK.

With the introduction of the Digital Battery Passport, the European Union is setting a new benchmark for transparency, compliance, and lifecycle management in the battery value chain. The Passport is a legally mandated digital dataset that accompanies a battery throughout its entire lifecycle. In accordance with the EU Battery Regulation (Article 77), it becomes mandatory from 18 February 2027 to industrial, electric vehicle (EV) and light mobility batteries. 

Each battery is linked to a unique digital identity, enabling authorised parties to access standardised information via interoperable systems. This creates a traceable data layer that links the stages of manufacture, use and disposal – something that has largely been missing from current waste management systems. 

Why Was It Introduced? 

The regulation is a response to a systemic challenge: fragmented and asymmetrical information flows across the entire life cycle of batteries. For companies responsible for the proper disposal of electronic equipment, this has long led to inefficiencies, safety risks and sub-optimal recycling rates. As the European Commission emphasises, the Digital Battery Passport is intended to close these gaps by ensuring uniform data availability across all stages of the value chain. A key issue it addresses is the lack of clarity regarding end-of-life responsibility, which has historically hindered the implementation of extended producer responsibility (EPR). 

Beyond compliance, the passport supports strategic policy objectives, including: 

• Increasing material recovery rates for critical raw materials 
• Improving traceability and environmental performance 
• Enabling circular business models, including second-life applications 

In this sense, it is not only a regulatory tool, but also an infrastructure for a data-driven circular economy. 

Who Does It Affect? 

From a legal perspective, the obligation applies to all economic operators placing relevant batteries on the EU market—manufacturers, importers, distributors, and Original Equipment Manufacturers (OEM). The passport introduces a new level of transparency that will likely become integral to compliance audits, reporting, and process optimization by the availability and expectation of using structured battery data. For producers, this marks a transition from largely material-drivenprocesses to increasingly data-informed decision-making. 

What Information Does It Contain? 

The Digital Battery Passport consolidates a comprehensive set of technical, environmental, and lifecycle-related data. Importantly, this information is not static but evolves over time, reflecting the battery’s actual use and condition. 

Core data categories include: 

• Material composition and battery chemistry
• Origin of raw materials and manufacturing details 
• Carbon footprint and sustainability metrics 
• Performance, durability, and state-of-health data 
• Repair, reuse, and repurposing history 
• End-of-life handling and recycling instructions 

For recyclers, this represents a significant operational shift. Access to standardised, reliable data enables more precise sorting, safer dismantling, and improved recovery of high-value materials. At the same time, it increases transparency regarding compliance with environmental and safety standards. 

Why Compliance Is Not Optional 

The Digital Battery Passport is the first legally binding Digital Product Passport (DPP) in the EU – and as such, it establishes a precedent for other product categories. Its implications go beyond reporting obligations. The passport will be directly linked to regulatory compliance, meaning that non-compliance can restrict market access. In practical terms, this elevates data management and traceability to a critical business function. It affects all players in the value chain, not only the manufacturers: While the highest responsibility of course lies on them, also importers, distributors and other economic players will have to play their role and ensure that all formal requirements of the batteries are met that they would like to put on the market within the EU. 

For producers the message is clear:
the transition to a data-centric regulatory environment is underway. Early alignment with the requirements of the Digital Battery Passport will not only ensure compliance but also position companies to operate more efficiently in an increasingly complex and resource-constrained system.

For manufacturers of electrical and electronic equipment (EEE), the crossed-out wheelie bin symbol is often seen as nothing more than a regulatory formality. In reality, it is a key instrument of EU waste policy, linking product design, consumer behaviour and end-of-life management within the circular economy. 

The symbol is required by Directive 2012/19/EU on waste electrical and electronic equipment (WEEE). Manufacturers placing electrical and electronic equipment on the EU market must ensure that products are marked in accordance with the following provisions: 

• Article 14 of the Directive (information for users) 
• The technical labelling standard EN 50419 

This obligation is not merely administrative in nature. It ensures that environmental information reaches the end user directly at the point where decisions about disposal are made. 

Why Most Symbols These Days Contain a Black Bar 

Many products have a solid black bar under the wheelie bin symbol. This detail has a specific legal meaning: the bar indicates that the product was placed on the EU market after 13 August 2005, the cut-off date specified in the original WEEE Directive, which makes it possible to distinguish between the following products: 

• Historical WEEE that was placed on the market before this date (for which the end user has the responsibility of collection and recycling)
• New WEEE that was placed on the market after this date (for which the producer has all related obligations, being the first one to put the product onto the market in a specific country) 

This distinction remains important for authorities and PROs, as it helps to determine financial responsibility for waste disposal. 

A Direct Means of Communication for End Users 

The crossed-out wheelie bin is one of the EU’s most direct means of communication in the field of environmental protection. It is intended to inform consumers that electrical and electronic equipment must not be disposed with unsorted waste. By stipulating that the label must be visible, legible and durable, the directive ensures that private end users as well as professionals understand that they must: 

• dispose equipment via separate collection systems 
• avoid unsorted and mixed waste 
• return products to authorised WEEE collection points 

This simple visual signal is not a sign that the product and the producer are registered and compliant, a frequent misunderstanding we are facing in our daily operations.

Why the Symbol Is Important For Producers 

From a systems perspective, correct labelling directly contributes to the efficiency of collection and material recovery. In this way, the symbol not only supports compliance with legal requirements, but also operational efficiency along the entire waste management chain. Clear information for end users helps to:

• reduce the amount of WEEE ending up in residual waste 
• increase recovery rates for valuable materials such as copper, aluminium and rare earth elements 
• limit environmental and health risks from hazardous components 
• improve overall collection rates for WEEE, an important performance indicator under EU law 

While authorities carry out awareness campaigns to improve separate collection, product labelling remains the only information permanently affixed to the device itself – it is therefore a fundamental element of the WEEE system. 

Should you require further information about the crossed-out bin icon or your obligations as a producer under EPR regulations, do not hesitate to reach out to us via our Quick Obligation Check.

Batteries may be small, but the regulatory changes around them are significant. Since January, the new EU Battery Regulation has begun reshaping compliance across Europe, with its key provisions officially binding as of August 2025. For manufacturers and distributors, this isn’t just a legal update – it’s a shift toward new reporting structures, revised categories and adjusted processes. So what does this transformation actually mean in day-to-day business terms? 

Until now, batteries have been reported primarily according to their chemistry and weight. With the new regulation, the focus is now more on the actual use of the battery in the respective device or area of application. The new classification comprises five categories: 

• Portable batteries (≤ 5 kg) – e.g. in mobile electrical devices 
• Industrial batteries (> 5 kg) – for industrial applications
• LMT batteries (Light Means of Transport) – e.g. for e-bikes or e-scooters 
• SLI batteries (Starting, Lighting, Ignition) – typically for vehicles with combustion engines 
• EV batteries – for electric and plug-in hybrid vehicles 

A good example is the rechargeable lithium-ion battery: it can be found in all five categories – from smartphones and power tools to electric cars. So it is not just the battery itself that is decisive for reporting, but what it is used for. 

Adjustments in Reporting: New Categories in the Reporting Systems 

To reflect this differentiation, the European take-back systems (PROs – Producer Responsibility Organisations) have revised their reporting categories. The PRONEXA reporting tool (CDM platform) already reflects these changes. Companies will see the new categories in their monthly volume reports from January onwards and will have to allocate their battery sales volumes accordingly. 

In practice, this means: 

• Products that were previously reported under old categories must be reassigned. 
• Correct classification according to application is crucial for legally compliant reports. 

Are There Any New Legal Obligations? 

For many battery manufacturers and distributors who are already registered, the basic obligations remain the same. Nevertheless, there are specific new requirements for action in individual countries. 

1. Example Germany: Some existing battery contracts with take-back systems must be resigned or amended to comply with the new regulatory requirements. 
2. Example Denmark: There is an important change for foreign manufacturers here: they must now also register and report batteries – both as spare parts and integrated into electrical appliances. 

Regulations have also been tightened in other countries where previously no reporting obligation existed for foreign producers. Companies must now also register and report there– in line with the regulations in other EU countries. 

New Price Lists and Conversion of Existing Reports 

With the new Battery Regulation, many PROs have also adjusted their price structures. This has several practical consequences: 

• Manufacturers must transfer their previously reported products to the new categories in order to be able to report correctly from January onwards. 
• In some countries, new registration requirements are being introduced for companies that were not previously subject to reporting obligations. 
• Existing contracts with take-back systems – for example, in Germany – may need to be updated. 

Conclusion:
Review Your Processes and Adjust Reports Now 

The new EU Battery Regulation does not introduce entirely new obligations, but rather a more precise, application-oriented system – with direct implications for reporting, contract structures and national registration requirements. 

Companies should: 

• assign their product portfolios to the new battery categories 
• review national specifications 
• review existing contracts and registrations 

If you are unsure about the new EU Battery Regulations and its impact on you as a producer, it is advisable to contact your responsible PRONEXA Compliance Specialist directly.
If you are not a PRONEXA customer yet, please use the QUICK OBLIGATION CHECK.

PRONEXA Compliance Specialists support companies in identifying necessary adjustments and implementing them in a legally compliant manner.

An important milestone will be the publication of the Design for Recycling (DfR) guidelines by January 2028. These guidelines will define when packaging is officially considered recyclable, and according to the PPWR, this requirement extends far beyond theoretical standards.  

Packaging must:  

• be sortable in existing waste streams
• be recyclable in efficient industrial processes, 
• produce secondary raw materials that can replace virgin materials. 

At the same time, recyclable packaging will be rewarded with lower EPR fees through eco-modulation, while formats that are difficult to recycle will be subject to higher costs. As existing forms of eco-modulation already show, implementing these changes will be challenging in practice and very difficult to monitor.  

2030: Recyclability as a Market Requirement 

From 2030, packaging must be at least 70% recyclable to enter the EU market. Stricter rules, including the Recycled at Scale (RaS) requirement from 2035, will tie recyclability to real recycling rates. Additional measures like single-use plastic bans and reuse targets will change packaging and infrastructure further. 

Mandatory Recycled Content in Plastics 

The PPWR sets required recycled content levels for plastic packaging:  

• 2030, ranges between 10% and 35%, based on plastic type,  
• 2040, rising to 25%–65%.  
• Exceptions cover some medical or pharmaceutical packaging, and packaging with less than 5% plastic. These rules aim to drive demand for high-quality recyclates in critical uses. 

By 2026, the European Commission will set standard rules for calculating and verifying recycled content to improve market transparency and regulation enforcement. Eco-modulation means packaging with higher recycled content may cost less, depending on national implementation.  

Recycled at Scale (RaS): Integrating Design With System Effectiveness 

The RaS requirement introduces an additional critical aspect. Packaging qualifies as recyclable only if it is recycled to a substantial degree within designated material streams. This criterion establishes a direct connection between product design and the real capabilities and performance of recycling systems. Although some requirements are still far off, current reports for packaging already demand recycling data and evidence. 

Packaging Data That You Are Required to Report 

We assist you with your packaging reporting and submit your regular reports to the PROs or authority bodies. In this report, you list the amount of packaging you introduce to the market or country. The authority uses this information to calculate the material recycling rates (%) of recycled packaging. After submitting the report with material and packaging amounts, an invoice will be generated. 

Reporting to PROs or Authority Bodies  

Report packaging volumes in kilograms for all packaging types you put on the market, specifying if they are for households or other uses. Include packaging made from these materials in your report:  

• cardboard/paper,
• wood,
• glass,
• metal (steel or aluminium),
• plastics and 6. other packaging materials (such as ceramics and textiles). 

Recyclability and Reporting by Recycling Grade
(e.g., Denmark, Sweden, Finland, France, UK)  

A number of countries have established graded recycling systems, featuring tiered fees according to the recyclability of packaging. These fees range from green (lower rates) to amber and red (higher rates).  

In Sweden, both rigid and flexible mono-material plastic packaging can be easily identified through modern sorting technology, which streamlines material separation and improves downstream recyclability. This results in higher recycling rates and significant cost reductions for customers. Moreover, bonuses are awarded for paper and cardboard that are not laminated or coated, as these materials dissolve more readily during recycling, especially within paper mills. 

To sum up, every EPR fee takes into account that mono-materials are simpler to sort and recycle, making them ideal for creating secondary raw materials. Regulations encourage replacing virgin materials with recycled alternatives. Additionally, colourinfluences sorting and recycling processes, which is why some countries require reporting by clear or coloured packaging. 

By adopting Design for Recycling (DfR) principles in your packaging, your organisation can fulfil regulatory obligations and lower expenses. 

Reporting Requirements for Single-Use Plastic (SUP) Products 

For packaging reports in Nordic countries like Sweden and Finland, companies must identify any single-use plastic items in their product portfolio. If your company has single-use plastic products (e.g. plastic carrier bags), you are required to report their quantities in your SUP submission.  
Future updates will cover more details on single-use plastics and packaging, including EPR stream information. 

Need Help With Complex Reports Across Different Countries?  

Contact us via our QUICK OBLIGATION CHECK to learn which obligations apply.
We provide consulting and operational support for importers, producers, and resellers of packaging and packaged goods. 

It’s a striking figure: every EU citizen generated 177.8 kg of packaging waste in 2023, according to Eurostat. The environmental and economic implications are impossible to ignore – escalating resource consumption, loss of valuable materials, and rising regulatory pressure on businesses. 

The EU’s response is the Packaging and Packaging Waste Regulation (PPWR). Unlike a directive, this regulation applies directly across all Member States since 11.02.2025, while most of its obligations and legal requirements will kick in as from 12 August 2026, leaving no room for national interpretation or delay. Its mission is clear: prevent unnecessary packaging, drive reuse, and significantly increase recycling rates. By 2030, at least 70% of all packaging waste must be recycled, with ambitious material-specific targets for plastics, paper, glass, metals, and wood. 

Are You a “Producer” Under the PPWR? 

But there is one aspect many companies underestimate: The PPWR introduces a new, much clearer definition of who is the “producer”. And this matters — because the “producer” becomes the central responsible party for compliance and Extended Producer Responsibility (EPR). 

This is where many businesses will be affected – even those who never considered themselves packaging producers before. The New PPWR Definition of “producer” (Art. 3.15) is defining a producer as the economic operator who first makes packaging or a packaged product available on the market of a Member State, whether as: 

• a manufacturer
• an importer 
• a distributor 
• an e-commerce operator 
• a brand owner 
• or a contract giver 

The objective is simple: every packaging unit should have one clearly identifiable responsible producer. 

The Contract Giver Becomes the Producer

The contract giver is automatically the producer – that is one of the most impactful changes. If you have packaging or packaged products manufactured under your own name or trademark, you are considered the producer, even if: 

• another company physically manufactures the product, 
• another brand name appears on the packaging, 
• production happens outside the EU. 

This means, the contract giver becomes legally responsible for the packaging. All EPR obligations fall to them, including fees, reporting, design requirements, and compliance documentation. 

Why This Matters for Your Business 

The new definition of a manufacturer under PPWR includes any natural or legal person who manufactures packaging or packaged products – or the customer who commissions this manufacturing. As a result, the roles of “manufacturer” and “producer” merge in many cases, thereby increasing responsibility. Responsibility may shift within a supply chain: companies that were previously ‘only distributors’ or “only brand owners” may now be classified as producers – with full compliance obligations. 

You should check: 

• Do you place packaging or packaged products on the EU market for the first time? 
• Do you sell under your own brand or trademark? 
• Do you commission manufacturing or packaging through third parties? 
• Do you import packaged goods into the EU? 
• Do you operate an online shop targeting EU customers? 

If any of the above points apply, you may be the obligated manufacturer under PPWR. You will then need to assess your role in the supply chain.

What you need to do now: 

• Map your packaging flow across countries and partners. 
• Analyse design, recyclability, and minimisation requirements. 
• Prepare for EPR obligations in all relevant Member States. 
• Establish documentation and conformity processes early. 
• From 2026, compliance will no longer be optional — and the responsibility will be clearly assigned. 

Need Help With EU Packaging Compliance? 

The PPWR is reshaping responsibilities across the entire packaging value chain.
If you are unsure whether your company is considered a “producer” or how the regulation affects you, please contact us by answering 5 simple questions in our Quick Obligation Check. 

Fundamental Changes Are Ahead

The new EU Battery Regulation (Regulation (EU) 2023/1542), which has now completely replaced the previous directive with phased obligations until 2030, fundamentally changes the way batteries are designed, placed on the market, managed and recycled. One of the most important changes is the transition from three battery types under the old Battery Directive to five clearly defined battery categories. 

The new categories determine which compliance obligations apply to your products, what documentation you need, how you must label and collect them – and ultimately, how costly and complex your obligations will be. 

Why Did the EU Move From 3 to 5 Categories? 

The old Battery Directive (2006/66/EC) relied on three broad categories: 

• Portable batteries 
• Industrial batteries 
• Automotive batteries 

These categories were too vague for today’s market, where batteries are embedded in nearly every product – from e-bikes to wearables to vehicles powered by high-capacity lithium packs. The result was inconsistent interpretation across Member States and unclear obligations for manufacturers. 

The 5 Battery Categories Explained – and What They Mean For You 

By distinguishing between very different use cases – from AA batteries to EV packs – the law can now set the right technical and environmental requirements for each type. This harmonised structure reduces national discrepancies, supports safer and more sustainable battery life cycles, and reflects the rapid rise of e-mobility and consumer electronics. In short, the new categories adapt the regulation to today’s technological realities and future-proof the EU battery market. 

1. Portable batteries 

Definition: Sealed, lightweight batteries (< 5 kg) used by consumers in everyday devices such as remote controls, toys, kitchen appliances, laptops and smartphones. 

Update:
– Stricter requirements for replaceability (from 2027, most portable batteries must be easily removable by the user)
– Stricter collection targets (63% by 2027, 73% by 2030)
– Higher minimum proportion of recycled materials 

Affected businesses: Electronics manufacturers, importers and online sellers, as well as all brands offering battery-powered consumer products on the EU market. 

2. Batteries for light mobility devices (LMT) as a new category 

Definition: Batteries used to power e-bikes, e-scooters, hoverboards or similar vehicles. 

Update as new category: The LMT market has grown explosively and no longer fit into the “portable” or “industrial” categories. Safety, fire hazards, transport issues and end-of-life disposal required separate regulations. 

Impact on businesses:
– Requirements for performance and safety testing
– CO2 footprint information (phased)
– Specific collection and recycling obligations
– Manufacturers and importers of e-bikes/e-scooters now bear full EPR responsibility without restrictions 

3. Starter, lighting and ignition batteries (SLI batteries) 

Definition: Batteries mainly used in vehicles to start engines and supply power for lighting and ignition. 

Update:
– Clearer distinction from EV batteries
– Specific regulations for durability, safety and labelling 

Affected businesses: Automotive suppliers, automotive manufacturers, aftermarket brands. 

4. Industrial batteries 

Definition: Batteries for industrial or professional use or any batteries weighing more than 5 kg that do not fall under other categories.
Examples: Forklift batteries, batteries for telecommunications base stations, ESS (Energy storage systems). 

Impact on businesses:
– Requirements for performance, durability and sustainability
– Mandatory due diligence in the supply chain
– Stricter recycling and reporting requirements 

5. Electric Vehicle (EV) Batteries as another new category 

Definition: Drive batteries for electric or hybrid vehicles. 

Update as a new category: The carbon footprint of these EV batteries, material composition (lithium, cobalt, nickel) and recycling value differ fundamentally from SLI or industrial batteries. 

Impact on businesses:
– Mandatory CO2 footprint disclosures
– Quotas for recycled content
– Battery passport requirements (from 2026)
– Manufacturer responsibility for collection, take-back and proper treatment
– Manufacturers must prepare for extensive documentation and traceability requirements 

What Companies Need to Do Now 

1. Clearly identify your battery category: Review your product portfolio and assign each battery to the correct category.
2. Review your Extended Producer Responsibility (EPR) obligations: Your obligations may have changed or expanded significantly.
3. Prepare for new technical and sustainability requirements: These include information on carbon footprint, durability testing and the interchangeability of portable batteries.
4. Adapt your supply chain and documentation processes: This applies in particular to electric vehicle and industrial batteries, which require due diligence systems and battery passports.
5. Update your compliance strategy before the regulations come into force: Penalties will be high, and national authorities are preparing for stricter enforcement. 

If you have any questions or need assistance in assessing the impact of the new battery regulation on your business, our team at PRONEXA is here to help. Contact us!

For years, companies have viewed waste management as a cost factor. Collection targets, reporting requirements, recycling obligations. Under Extended Producer Responsibility (EPR), these were strictly viewed as compliance tasks rather than strategic opportunities. But something has changed. Quietly and steadily, a new paradigm is shifting governments’ view of waste and manufacturers can no longer afford to ignore it. 

Welcome to the age of urban mining, where yesterday’s discarded products become tomorrow’s competitive advantage in the supply chain. This shift is fully in line with the European Green Deal, which places the circular economy, resource efficiency and reduced dependence on fragile raw material imports at the heart of European industrial strategy. 

The Hidden ‘Mines’ in Our Cities 

Every laptop, every battery, every vehicle and every device contains metal and material deposits that are becoming increasingly difficult – and politically risky – to extract from nature. Cobalt from conflict zones, rare earths from geopolitically tense regions and critical raw materials tied to volatile global markets. 

But while the world worries about supply shortages, these very materials lie in our cities, waiting to be recycled. The richest mines are no longer underground, but in drawers, garages and recycling centres. This is the logic that shapes today’s waste regulations. The pressure to recycle is not only ecological, but also strategic. In other words, waste isn’t leaving your value chain. It’s coming back as a resource. 

How Urban Mining Is Practically Implemented 

Three changes are already underway: 

1. Eco-design: products designed for recycling 

Manufacturers are redesigning products so that they can be easily dismantled, sorted and recycled. What used to be considered a cost factor at the end of a product’s life is now becoming an opportunity for material recovery. 

2. Better collection and traceability 
With the introduction of digital product passports, return systems and more transparent collection channels, it will be possible to better track where valuable materials end up after use. This will ultimately enable companies to recover these materials more reliably and reintegrate them into production.

3. New cooperation models 

Producers, compliance systems and recycling companies are working more closely together than ever before. When they share data and plans, this leads to higher recovery rates, lower costs and more stable access to scarce materials. 

Why This Is Important for Companies Right Now 

Companies that still view waste solely as a compliance issue are missing the big picture. Urban mining is becoming an indispensable strategy for 

• reducing dependence on unstable global supply chains,
• lowering material costs, 
• achieving circular economy goals, and 
• strengthening brand and ESG performance. 

Working Together to Make Circularity Happen 

Together, both producers, PROs, and ourselves at PRONEXA can work more closely together to make the circular economy a reality and improve sustainability.

In case of any questions about Urban Mining, your contribution as a Producer and EPR in general contact us today!

Since the new EU Battery Regulation came into force in Mid-August, the industry has been buzzing: Manufacturers, importers, and distributors across Europe are now facing a wave of new obligations, unclear definitions, and unanswered questions. From the upcoming EU Battery Passport to new rules on recycled content, carbon footprint declarations, and sustainability design – with the new Battery Regulation the regulatory landscape is becoming more complex than ever.  
 
However, some things remain unchanged: If your electrical or electronic products contain batteries, you still have EPR obligations under both WEEE and Battery legislation. Still, this rule continues to surprise many companies. 

WEEE and Battery Means Dual EPR Responsibility 

We regularly receive inquiries from companies bringing Electrical and Electronic Equipment (EEE) onto the market in various EU countries, being uncertain on “Who is the producer?” They struggle with the differentiation of the “manufacturer” of the product and the role as “producers”, responsible under EPR legislation. While those companies often “only” ask for support on WEEE, we frequently find out during our intensive assessment that their WEEE products also contain batteries. Therefore – in addition to their WEEE EPR obligations – these companies are considered “producers” also for the batteries and are subject to the same obligations under Extended Producer Responsibility (EPR) rules  that the new regulation puts in place.

Here are some examples of electrical devices that you would not immediately suspect to contain batteries: 

• Computer motherboards:
  They contain a small button cell battery that supplies power to store settings (such as system time and configurations) even when the PC is turned off and
  disconnected from the power supply 

• Smart kitchen appliances with integrated rechargeable batteries 

• Electric toothbrushes or shavers with built-in power cells 

• IoT and smart home devices powered by button cells or small batteries 

• Cordless tools with lithium-ion packs 

• Children’s toys or gadgets with internal batteries 

Companies placing those products on the market must register both – as WEEE and a Battery producer. 

The Battery EPR Obligation Remains – Even Under the New Regulation 

While the new Battery Regulation introduces major changes – such as stricter sustainability criteria, collection targets and digital traceability – the core compliance duties remain fully intact: 

• Registration with the relevant authorities

• Reporting of batteries placed on the market 

• Take-back and recycling obligations 

• Labeling and documentation requirements

These foundational rules continue to apply, regardless of how the upcoming technical details on the Battery Passport or carbon footprint reporting evolve. 

Marketplaces Are Stepping Up Compliance Checks 

Another important development: Online marketplaces such as Amazon, eBay or Otto are increasingly required to verify the EPR compliance of all sellers. In practice, this means: 

• Without a valid Battery registration number, sellers cannot list their products

• Marketplaces perform automated compliance checks before listings go live

• Missing registrations can lead to sales bans or delistings almost instantly

• For small and mid-sized producers, this can quickly result in disruptions to sales channels or even penalties

What Producers Should Do Now 

If you’re a manufacturer or importer of electrical devices, take a moment to review your compliance setup: 

• Do your products contain batteries – even small or built-in ones? 

• Are you registered under the national Battery EPR scheme? 

• Are your volume reports and labeling up to date? 

• Can your products legally be sold via online marketplaces? 

Establishing a combined EPR strategy for WEEE, Batteries, and Packaging can prevent compliance gaps, duplicate filings, and unnecessary costs.

If you have any questions about BATT-EPR, please do not hesitate to contact us at PRONEXA.